I'm a bit baffled at Googles implementation here. They have turned a single decision (though at a high court) into a seemingly automated process where everyone can have stuff removed that just mentions their name by filling out some web form:
Theres no obligation to go that far. Make people pay a lawyer when they want to get something removed.
Basically, treat it as the DMCA requests: remove the stuff and post the full request on a ChillingEffects-like site, and hint at that when a search included removed results.
According to Google, the process isn't automated. The submission process is, but each request is reviewed individually (and according to some reports, that appears to be true).
Google cannot post the takedown requests on a separate site, either. "Stop processing data tied to a person" means "stop processing data tied to that person", not with an invisible "except for keeping it accessible through a backdoor" clause.
Google has two problems. One, the directive (95/46/EC [1]) is almost two decades old. It pretty much predates search engines. Under article 7 (f) of the directive, Google has only limited rights to process personal data, and only where Google's interests (and those of the public) override the individual's right to privacy. That is normally a pretty sensible clause, except where search engines function as primary access pathways to journalistic publications; something that couldn't really be foreseen in 1995.
The other problem is that the ECJ handed down a narrow ruling. It said that in a specific 16-year old civil case (a debt that has long since been paid off) where there was no discernible public interest, the right to privacy outweighed the freedom of expression. The court also didn't give any other guidelines, other than cautioning that sufficient public interest (such as the data subject being a public figure) freedom of expression could outweigh the right of privacy.
The court probably issued a narrow ruling in order to defer having to decide the difficult underlying issue of how privacy and freedom of expression are to be balanced in general, but that doesn't help Google. Google had to weigh its own economic interest in providing meaningful search results against the risk of having to litigate the issue for a large number of cases individually.
An automated process is cheaper than dealing with lawyers. It could also be that Google made it this easy in order to make a point that the law is a bad idea.
https://support.google.com/legal/contact/lr_eudpa?product=we...
Theres no obligation to go that far. Make people pay a lawyer when they want to get something removed.
Basically, treat it as the DMCA requests: remove the stuff and post the full request on a ChillingEffects-like site, and hint at that when a search included removed results.